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Issues: Whether converting chromium and manganese ore fines into briquettes by mixing them with binders amounted to manufacture and rendered the product classifiable as concentrates.
Analysis: The activity involved only mixing ore fines with binding agents and mechanically converting them into briquettes. The essential feature of concentration under the HSN Explanatory Notes is removal of part or all of the foreign matter by special treatment, while agglomeration by pelleting or briquetting may be relevant only where it is part of such concentration process. On the facts found, no foreign matter was removed, no sintering or similar concentration process was carried out, and the process did not alter the basic character of the ore so as to amount to manufacture. The earlier Tribunal decisions on coal briquettes and manganese ore agglomeration supported the same view.
Conclusion: The process of converting ore fines into briquettes did not amount to manufacture and the Revenue's appeal failed.
Ratio Decidendi: Where ore fines are merely agglomerated into briquettes with binders, without removal of foreign matter or any equivalent concentration process, the activity does not constitute manufacture.